Respondent Holly Township appeals as of right from a judgment
of the Tax Tribunal granting tax-exempt status to petitioner Rose
Hill Center, Inc, a treatment facility for mentally ill adults.
We affirm in part, reverse in part, and remand.

Petitioner is a nonprofit corporation. On August 24, 1990,
petitioner acquired a 372-acre parcel of land in Holly Township
and subsequently constructed two residential buildings on it. The
buildings are operated as a treatment center for mentally ill
adults and are occupied by approximately thirty patients.

In 1993, the property was assessed at $1,516,100. Petitioner
appealed the assessment to the township board of review. The
board rejected petitioner’s challenge. On June 20, 1993,
petitioner filed an appeal of that decision with the Michigan Tax
Tribunal. On May 26, 1994, petitioner amended the petition to
include a challenge to the 1994 assessment of the property.

On October 27, 1994, the parties submitted a stipulated
statement of facts. The parties agreed that the subject property
was inspected and licensed as a mental health provider by the
Michigan Department of Social Services and that petitioner had
applied for classification as a public charitable organization
under § 501(c)(3) of the Internal Revenue Code.[1]

In support of its claim of exemption, petitioner argued that
it is exempt from property taxes as a hospital or facility used
for public health purposes under MCL 211.7r; MSA 7.7(4-o).[2]
Respondent contended that petitioner is not operated for public
health services because it is not licensed under the Public
Health Code and does not provide the type of services typically
associated with public health providers. Respondent further
asserted that, even assuming that petitioner is operated for
public health services, 255 acres of the property are not used in
connection with the public health purpose and therefore are
subject to tax.

A hearing on petitioner’s claim was held on September 26,
1995. At the conclusion of the hearing, the tribunal took the
matter under advisement. On October 23, 1995, the tribunal issued
a judgment in favor of petitioner. The tribunal found that the
entire parcel is exclusively utilized for public health purposes
and is therefore exempt from taxation. Respondent appeals.

I

Respondent first argues that petitioner is not entitled to a
tax exemption under MCL 211.7r; MSA 7.7(4-o). Judicial review of
a determination by the Tax Tribunal is limited to determining
whether the tribunal made an error of law or applied a wrong
principle. Const 1963, art 6, § 28; Comcast Cablevision
of Sterling Heights, Inc v Sterling Heights, 218 Mich App 8,
11; 553 NW2d 627 (1996). Generally, this Court will defer to the
Tax Tribunal’s interpretation of a statute that it is delegated
to administer. Maxitrol Co v Dep’t of Treasury, 217 Mich
App 366, 370; 551 NW2d 471 (1996). The factual findings of the
tribunal are final, provided that they are supported by
competent, material, and substantial evidence on the whole
record. Comcast, supra.

The Tax Tribunal found that petitioner’s property is exempt
from taxation pursuant to MCL 211.7r; MSA 7.7(4-o). The statute
provides:

The real estate and building of a clinic erected,
financed, occupied, and operated by a nonprofit corporation
or by the trustees of health and welfare funds is exempt from
taxation under this act, if the funds of the corporation or
the trustees is derived solely from payments and
contributions under the terms of collective bargaining
agreements between employers and representatives of employees
for whose use the clinic is maintained. The real estate with
the buildings and other property located on the real estate
on that acreage, owned and occupied by a nonprofit trust and
used for hospital and public health is exempt from taxation
under this act, but not including excess acreage not actively
utilized for hospital or public health purposes and real
estate and dwellings located on that acreage used for
dwelling purposes for resident physicians and their families.
[MCL 211.7r; MSA 7.7(4-o).]

Statutory interpretation is a question of law subject to de
novo review on appeal. Golf Concepts v Rochester Hills,
217 Mich App 21, 26; 550 NW2d 803 (1996). The primary goal of
statutory interpretation is to ascertain and give effect to the
intent of the Legislature in enacting a provision. Farrington
v Total Petroleum, Inc, 442 Mich 201, 212; 501 NW2d 76
(1993). Statutory language should be construed reasonably,
keeping in mind the purpose of the statute. The first criterion
in determining intent is the specific language of the statute. If
the statutory language is clear and unambiguous, judicial
construction is neither required nor permitted, and courts must
apply the statute as written. Barr v Mount Brighton Inc,
215 Mich App 512, 516-517; 546 NW2d 273 (1996). However, if
reasonable minds can differ regarding the meaning of a statute,
judicial construction is appropriate. Yaldo v North Pointe Ins
Co, 217 Mich App 617, 620-621; 552 NW2d 657 (1996).

The tribunal found that "Rose Hill Center services are
for public health purposes." The phrase "public health
purposes" is not defined in the statute. When, as in this
case, a word is not defined in the statute, a court may consult
dictionary definitions. Yaldo, supra at 621. The
American Heritage Dictionary: Second College Edition defines
"public health" as

The art and science of protecting and improving community
health by means of preventative medicine, health education,
communicable disease control, and the application of the
social and sanitary sciences.

In the instant case, the tribunal found that petitioner was
engaged in the provision of services to mentally ill patients.
These services include psychiatric evaluation and diagnosis, the
prescription and dispensation of medication, and rehabilitation
and reintegration programs. Petitioner is staffed by a
psychiatrist, psychiatric nurses, and social workers and provides
twenty-four-hour care to its patients. Petitioner is open to
mentally ill adults without regard to race, religion, or sex.
Petitioner accepts patients covered by Medicare and Medicaid, as
well as by private sources.

After considering these facts, we believe that petitioner can
reasonably be considered to be operating a facility for
"public health purposes." We therefore conclude that
the Tax Tribunal did not make an error of law or apply a wrong
principle. The tribunal’s decision constitutes a reasonable
interpretation of the statute and is therefore entitled to
deference. See Maxitrol, supra.

Respondent contends that because petitioner is not licensed
under the Public Health Code, it is not entitled to the
exemption. We disagree. The statute does not contain any language
restricting the exemption to facilities licensed under the Public
Health Code. If the Legislature had intended such a limitation,
it could easily have included such language.

II

Respondent next argues that the tribunal erred in finding that
petitioner was entitled to an exemption for all 372 acres of the
subject property. Respondent contends that since only
recreational and social activities are performed on the land
surrounding the 120-acre central campus, there is insufficient
evidence to support the tribunal’s conclusion that the entire
parcel is used for public health purposes. Furthermore,
respondent asserts that even if the social and recreational
activities are for public health purposes, the irregular nature
of the patients’ use of the outlying portions of the property
requires a finding that it is not actively used in any sense.

At the hearing on this issue, evidence was presented that the
372-acre parcel consists of a central complex of approximately
seven residential buildings and a community center. Surrounding
this central area are a working farm, pasture, woods, lakes, and
marsh areas. Petitioner’s executive director, Ronald Stuursma,
testified that most of the patients suffer from chronic mental
illness. The farm is run by two employees who are assisted by the
patients as part of their treatment program. The patients also
assist in caring for the animals and distributing the crops after
harvest. The woods, lakes, and marsh areas are used sporadically
for recreational activities such as hiking, fishing, swimming,
and winter sports. These recreational activities assist the
treatment of the patients by providing motivation and exercise
and aiding the development of interpersonal relationships between
the residents and staff. Stuursma also testified that the open
spaces were useful for dealing with agitated patients, as the
staff would send them for walks, alone or accompanied by a staff
member, depending on the patient’s condition.

On cross examination, Stuursma admitted that no formal medical
care or treatment is performed outside of the buildings. Stuursma
also stated that although the program might not operate in the
same manner, it could function solely on the 120 acres serving as
the central campus.

In its opinion, the tribunal found that the entire parcel is
used for public health purposes "because the property is
used exclusively for the care and rehabilitation of its
patients." The tribunal determined that care of the farm
animals, working on the farm, and using the surrounding area for
recreational activities are all part of the therapy provided. The
open spaces are beneficial in treating the patients and in
addition provide a buffer between petitioner’s facilities and its
neighbors.

In Saginaw General Hosp v Saginaw, 208 Mich App 595;
528 NW2d 805 (1995), this Court addressed whether a freestanding
day-care center for the exclusive use and benefit of hospital
employees was exempt from taxation under MCL 211.7r; MSA
7.7(4-o). Evidence was presented that the day-care center was
necessary to properly staff the hospital because the hospital
employees’ unusual schedules precluded utilization of other
child-care services. The hospital had concluded that opening the
day-care center would reduce employee turnover, absenteeism, and
tardiness. Id. at 596-597. This Court held that in
granting a tax exemption to a hospital, only those facilities
that are reasonably necessary for the competent operation of the
hospital should receive tax exempt status. Id. at 599.
Under this standard, the Saginaw panel held that the day
care center qualified as property used "for hospital or
public health purposes." Id. at 599-601.

From the evidence presented below, it is clear that the entire
parcel is beneficial to petitioner in treating its patients.
However, the tribunal did not apply the standard set forth in Saginaw
General Hosp. While the entire parcel may be beneficial to
petitioner, it is not certain that the entire parcel is
reasonably necessary to the performance of petitioner’s public
health function. Accordingly, we reverse that part of the
tribunal’s order finding the entire property exempt from taxation
and remand for a determination of what portion of the property is
reasonably necessary for the operation of petitioner’s facility.

Affirmed in part, reversed in part, and remanded. We do not
retain jurisdiction. No taxable costs pursuant to MCR 7.219,
neither party having prevailed in full.

[2]Petitioner also argued that it
was exempt from taxation pursuant to MCL 211.7o; MSA 7.7(4-l),
the exemption for charitable organizations. Because the tribunal
found that petitioner was entitled to an exemption under MCL
211.7r; MSA 7.7(4-o), it did not address whether petitioner was
entitled to an exemption as a charitable organization.